09/08/2003
We are a commercial bank with a large number of business accounts. Many of these accounts have numerous signers who are bookkeepers and the like with no authority or control. Are we required to collect the ID of these individual as well as those with authority and control? Or are we permitted to collect the only ID of those who are in authority/control of the company as demostrated on a corporate resolution or similar documentation?
09/08/2003
Prior to the passing of the USA Patriot Act, what was the responsibility of a national bank in verifying the "new account" customer's identification before opening a new account? I know in the USA Patriot Act, Section 326 clearly addresses the current requirements. I am wondering what regulations were in place as of 1/2002.
09/08/2003
09/02/2003
In opening corp, LLC, and partnership accounts, we do Telecheck and CheqSystems on the principals. We have them sign an authorization. We are now considering not doing that process. We would still require the appropriate documentation and could verify with the Secretary of State. I would like to know what your opinion is regarding verifying through CheqSystems and Telecheck or similar systems of the principals for these business accounts.
09/01/2003
09/01/2003
Commonly cited violations have long been a source of important information for the design and management of compliance programs.
09/01/2003
We are down to the wire for adoption and implementation of a customer identification program. There has been a lot of talk and more worry about what is or should be involved.
08/25/2003
How does the new Patriot Act regarding CIP address closed accounts? What I mean is if a customer has closed an account but still is on our operating system with all information, are they considered a new customer if they come in to open a new account?
08/18/2003
The CIP ruling did not specifically address the mortgage lenders. How can we or when should we identify customers on mail applications, telephone applications or when the loan is being handled by a representative with a power of attorney and the borrower cannot be present?
08/04/2003
Our bank accepts funds via wire transfer from a broker who places the funds with the bank on behalf of public school districts. The bank opens CDs with the funds in the name of the school district. What documentation will satisfy customer identification requirements?